Appendix B

Contributors to the Supplement

May 2006 B-1 NUREG-1437, Supplement 24

Appendix B: Contributors to the Supplement

The overall responsibility for the preparation of this supplement was assigned to the Office of

Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). The statement was

prepared by members of the Office of Nuclear Reactor Regulation with assistance from other

NRC organizations, the Lawrence Livermore National Laboratory, Argonne National Laboratory,

Energy Research Incorporated, and the Information Systems Laboratory.

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Leslie C. Fields Nuclear Reactor Regulation Project Manager |

Rani L. Franovich Nuclear Reactor Regulation Branch Chief |

Jennifer A. Davis Nuclear Reactor Regulation Backup Project |

Manager/Cultural Resources

Michael T. Masnik Nuclear Reactor Regulation Aquatic and Terrestrial

Resources

Stacey Imboden Nuclear Reactor Regulation Health Physics

Richard Emch Nuclear Reactor Regulation Health Physics |

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation

Alternatives

William L. Dam(A) Nuclear Reactor Regulation Socioeconomics/Land Use |

Samuel Hernandez Quinones Nuclear Reactor Regulation Project Support/Backup Project

Manager |

LAWRENCE LIVERMORE NATIONAL LABORATORY(B) |

Bruce McDowell Task Leader

Lily A. Sanchez Deputy Task Leader

Jessie Coty Aquatic Ecology

Lisa Crawford Alternatives

Paul McGuff Cultural Resources

Crystal Quinly Land Use, Related Federal

Programs

Warren Rued Socioeconomics

Karen McWilliams Technical Editor

Nancy Woods Technical Editor |
Appendix B

Name Affiliation Function or Expertise

NUREG-1437, Supplement 24 B-2 May 2006

Celina Chance Administrative Support

| Kim Martin Administrative Support

ARGONNE NATIONAL LABORATORY(C) |

Timothy Allison Socioeconomics

Halil I. Avci Radiation Protection

John Krummel Terrestrial Ecology

Mike Lazaro Meteorology, Air Quality

David S. Miller Water Use; Hydrology

| INFORMATION SYSTEMS LABORATORY

Kim Green Severe Accident Mitigation

Alternatives

Bob Schmidt Severe Accident Mitigation

Alternatives

| (A) No longer with the NRC.

| (B) Lawrence Livermore National Laboratory is operated for the U.S. Department of Energy by the University of

California.

| (C) Argonne National Laboratory is operated for the U.S. Department of Energy by the University of Chicago.
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to Nine Mile Point Nuclear Station, LLC’s Application for

License Renewal of Nine Mile Point, Units 1 and 2

May 2006 C-1 NUREG-1437, Supplement 24

Appendix C: Chronology of NRC Staff Environmental

Review Correspondence Related to Nine Mile Point

Nuclear Station, LLC’s Application for License

Renewal of Nine Mile Point, Units 1 and 2

This appendix contains a chronological listing of correspondence between the U.S. Nuclear

Regulatory Commission (NRC) and Nine Mile Point Nuclear Station, LLC (NMPNS), and other

correspondence related to the NRC staff's environmental review, under Title 10 of the Code of

Federal Regulations (CFR) Part 51, of NMPNS's application for renewal of Nine Mile Point,

Units 1 and 2, operating licenses. All documents, with the exception of those containing

proprietary information, are available for public inspection in the NRC’s Agencywide Documents

Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is

accessible at http://adamswebsearch.nrc.gov/dologin.htm. From this site, the public can gain

access to text and image files of NRC's public documents. The ADAMS accession number for

each document is included below. 

May 26, 2004 Letter from Mr. James A. Spina, Constellation, to NRC submitting the

applications for the renewal of the operating licenses for NMP, Units 1

and 2 (Accession No. ML041490213 and ML041490213).

May 28, 2004 NRC Press Release No. 04-065 "NRC Announces Availability of License

Renewal Application for Nine Mile Point, Units 1 and 2" (Accession No.

ML041490358).

June 1, 2004 NRC staff letter to Mr. Peter E. Katz, Constellation, regarding the receipt

and availability of the license renewal applications for Nine Mile Point,

Units 1 and 2 (Accession No. ML041540092).

June 8, 2004 Federal Register Notice of Receipt and Availability of Application for

Renewal of Nine Mile Point Nuclear Station Facility Operating Licenses

No. DPR-63 and NPF-69 for an Additional 20-Year Period (69 FR 32069-

32070)

June 28, 2004 NRC staff letter to Ms. Mary Bennett, Penfield Library, regarding the

maintenance of documents related to the NMP Units 1 and 2 license

renewal review (Accession No. ML041830631).

July 21, 2004 NRC Press Release No. 04-088 "NRC Announces Opportunity for

Hearing on Application to Renew Nine Mile Point Operating Licenses

(Accession No. ML042030444).
Appendix C

NUREG-1437, Supplement 24 C-2 May 2006

July 21, 2004 Federal Register Notice of Acceptance for Docketing of the Application

and Notice of Opportunity for Hearing Regarding the Renewal of Facility

Operating Licenses Nos. DPR-63 and NPF-69 for an Additional 20-Year

Period (69 FR 43631-43633).

July 29, 2004 NRC staff letter to Mr. Don Klima, Director, Advisory Council on Historic

Preservation, regarding the Nine Mile Point license renewal review

(Accession No. ML042160074).

August 2, 2004 Letter from the NRC to Mr. James A. Spina, NMPNS, forwarding the

Notice of Intent to Prepare an environmental impact statement and

conduct scoping process for Nine Mile Point Nuclear Station, Units 1

and 2 license renewal (Accession No. ML042160153).

August 6, 2004 Letter from Constellation Energy to Mr. Vance Bar, New York State

Department of State, relating to the Coastal Management Program

Consistency Determination (Accession No. ML042300154). 

August 9, 2004 Letter to Mr. Raymond A. Mosley, Office of the Federal Register,

requesting for immediate public inspection regarding the Notice of Intent

to prepare an environmental impact statement and conduct scoping

process for Nine Mile Point Nuclear Station, Units 1 and 2 license renewal

(Accession No. ML042230182).

August 11, 2004 Federal Register Notice of Intent to Prepare an Environmental Impact

Statement and Conduct Scoping Process of Facility Operating License

Nos. DPR-63 and NPF-69 (69 FR 48900-48901).

August 11, 2004 Letter from the NRC to Ms. Bernadette Castro, Commissioner, New York

State Office of Parks, Recreation and Historic Preservation, inviting

participation in the scoping process relating to the Nine Mile Point Nuclear

Station, Units 1 and 2 license renewal review (Accession No.

ML042250207).

August 11, 2004 NRC staff letter to Mr. Leo R. Henry, Chief, Tuscarora Nation, inviting

participation in the scoping process relating to Nine Mile Point Nuclear

Station, Units 1 and 2 license renewal review (Accession No.

ML042250372).

August 11, 2004 NRC staff letter to Mr. Emerson Webster, Chief, Tonawanda Band of

Senecas, relating to the Nine Mile Point Nuclear Station, Units 1 and 2

license renewal review (Accession No. ML042250412).
Appendix C

May 2006 C-3 NUREG-1437, Supplement 24

August 11, 2004 NRC staff letter to Mr. Ricky L. Armstrong, President, Seneca Nation of

Indians, relating to the Nine Mile Point Nuclear Station, Units 1 and 2

license renewal review (Accession No. ML042250437).

August 11, 2004 NRC staff letter to Mr. Raymond Halbritter, Representative, Oneida Indian

Nation of New York, relating to the Nine Mile Point Nuclear Station, Units

1 and 2 license renewal review (Accession No. ML042260238).

August 11, 2004 NRC staff letter to Mr. Clint Half Town, Chief, Cayuga Nation of New

York, relating to the Nine Mile Point Nuclear Station, Units 1 and 2 license

renewal review (Accession No. ML042260230).

August 11, 2004 NRC staff letter to Mr. Irving Powless, Jr., Chief, Onondaga Nation,

relating to the Nine Mile Point Nuclear Station, Units 1 and 2 license

renewal review (Accession No. ML042260213).

August 12, 2004 NRC staff letter to Mr. Jim Ransom, Chief, St. Regis Band of Mohawk

Indians, relating to the Nine Mile Point Nuclear Station, Units 1 and 2

license renewal review (Accession No. ML042260408).

August 12, 2004 NRC staff letter to Ms. M. Terrance, Chief, St. Regis Band of Mohawk

Indians, relating to the Nine Mile Point Nuclear Station, Units 1 and 2

license renewal review (Accession No. ML042260460).

August 12, 2004 NRC staff letter to Ms. Barbara Lazore, Chief, St. Regis Band of Mohawk

Indians, relating to the Nine Mile Point Nuclear Station, Units 1 and 2

license renewal review (Accession No. ML042260489).

August 20, 2004 NRC meeting notice informing public of meetings to be held in Oswego,

New York, to discuss the environmental scoping process for Nine Mile

Point Nuclear Station, Units 1 and 2 license renewal application

(Accession No. ML042330512).

August 24, 2004 NRC staff letter to Mr. Marvin Moriarty, U.S. Fish and Wildlife Service,

requesting a list of protected species within the area under evaluation for

the Nine Mile Point Nuclear Station, Units 1 and 2 (Accession No.

ML042380602).

September 9, 2004 NRC Press Release No. I-04-042, "NRC Seeks Public Input on

Environmental Impact Statement for Proposed Nine Mile Point Nuclear

Plant License Renewal" (Accession No. ML042530638).
Appendix C

NUREG-1437, Supplement 24 C-4 May 2006

September 16, 2004 NRC staff letter to Ms. Natalie Roy, Oswego County Health Department,

regarding the Nine Mile Point Nuclear Station, Units 1 and 2 license

renewal review (Accession No. ML042610263).

September 18, 2004 Email from Mr. Farouk Baxter providing scoping comments related to the

Nine Mile Point Nuclear Station, Units 1 and 2 license renewal review

(Accession No. 050040016).

October 12, 2004 Letter to NRC from Mr. William A. Barclay, Assemblyman, 12th District,

providing scoping comments related to the Nine Mile Point Nuclear

Station, Units 1 and 2 license renewal review (Accession No.

ML050050455).

October 20, 2004 NRC staff letter to Mr. James Spina, NMP, forwarding request for

additional information regarding severe accident mitigation alternatives for

the Nine Mile Point Nuclear Station, Units 1 and 2 (Accession No.

ML042940508).

November 3, 2004 Letter from Mr. David A. Stilwell, U.S. Fish and Wildlife Service, providing

a list of protected species within the area under evaluation for the Nine

Mile Point Nuclear Station, Units 1 and 2 (Accession No. ML043240317).

November 4, 2004 Summary of public scoping meetings to support the review of Nine Mile

Point Nuclear Station, Units 1 and 2 license renewal application

(Accession Nos. [ADAMS Package No., ML043130403], ML043130425 -

[Meeting Summary], ML043130369 [Afternoon Transcript], ML043130393

[Evening Transcript], ML043130442 [Meeting Slides]).

November 5, 2004 Summary of telephone conference conducted on October 4, 2004, with

Constellation to discuss severe accident mitigation alternative request for

additional information for Nine Mile Point Nuclear Station, Units 1 and 2

(Accession No. ML043130260).

November 7, 2004 NRC staff letter to Mr. Michael Stoll, U.S. Fish and Wildlife Service,

requesting a list of protected species within the area under evaluation for

the Nine Mile Point Nuclear Station, Units 1 and 2 (Accession No.

ML043140284). 

December 6, 2004 Letter from NMPNS to NRC supplying additional information regarding

severe accident mitigation alternatives for the Nine Mile Point Nuclear

Station, Units 1 and 2 (Accession No. ML043490360).
Appendix C

May 2006 C-5 NUREG-1437, Supplement 24

December 29, 2004 NRC staff email to Mr. Farouk Baxter, regarding scoping comments

related to the Nine Mile Point Nuclear Station, Units 1 and 2 license

renewal review (Accession No. MLML043650417).

January 5, 2005 NRC staff letter to Mr. James A. Spina, NMPNS, transmitting the

environmental scoping summary report associated with the staff's review

of the Nine Mile Point Nuclear Station, Units 1 and 2 (Accession No.

ML040900537).

March 3, 2005 Letter from Mr. Timothy J. O’Connor, Constellation, to NRC submitting a

request to recover the quality of the License Renewal Application for Nine

Mile Point Units 1 and 2. (Accession No. ML050680270).

June 30, 2005 Letter from Constellation Energy to Mr. John Feltman, New York State

Department of Environmental Conservation, relating to the Joint

Application for Permit 401 Water Quality Certification (Accession No.

ML052310320)

July 14, 2005 Letter from Mr. James A. Spina, Constellation, to NRC submitting the

Nine Mile Point amended license renewal application to the original

license renewal application for NMP, Units 1 and 2 (Accession No. 

ML052000163).

August 5, 2005 Letter from Constellation to Mr. John Feltman, New York State

Department of Environmental Conservation, providing a CD containing a

copy of the amended LRA and a copy of the transmittal letter. (Accession

No. ML052310319).

August 5, 2005 Letter from Constellation to Ms. Alyse Peterson, New York State Energy |

Research and Development Authority, providing a CD containing a copy

of the amended LRA and a copy of the transmittal letter. (Accession No.

ML052310317).

August 5, 2005 Letter from Constellation to Mr. Vance Barr, New York State Department |

of State division of Coastal Resources, providing a CD containing a copy

of the amended LRA and a copy of the transmittal letter. (Accession No.

ML052310315).

September 29, 2005 NRC staff letter to Mr. James A. Spina, Nine Mile Point Nuclear Station, |

regarding the availability of the Draft Supplement 24 to the GEIS, related |

to the license renewal application for Nine Mile Point, Units 1 and 2 |

(Accession No. ML052720589) |
Appendix C

NUREG-1437, Supplement 24 C-6 May 2006

| September 29, 2005 NRC staff letter to U.S. Environmental Protection Agency transmiting

| Draft Supplement 24 to the GEIS, regarding the license renewal

| application for Nine Mile Point, Units 1 and 2 (Accession No.

| ML052730073)

| October 6, 2005 Federal Register Notice of Availability of the Draft Supplement 24 to the

| Generic Environmental Impact Statement and Public Meeting for the

| License Renewal of Nine Mile Point, Units 1 and 2 (70 FR 58489-58490)

| October 13, 2005 NRC meeting notice announcing public meeting in Oswego, New York on

| November 17, 2005, to discuss the Draft Supplemental Environmental

| Impact Statement for license renewal of Nine Mile Point, Units 1 and 2

| (Accession No. ML052900180)

| October 20, 2005 NRC Press Release No. I-05-053, “NRC issues draft environmental report

for Nine Mile Point license renewal, announces November 17th | public

meeting” (Accession No. ML052930368)

| November 25, 2005 Letter from Ms. Nancy Herter, New York State Office of Parks, Recreation

| and Historic Preservation, to NRC transmitting comments on the Draft

| Supplement 24 to the GEIS, related to the license renewal application for

| Nine Mile Point, Units 1 and 2 (Accession No. ML053430114)

| December 15, 2005 Letter from Mr. James Spina, NMP, to NRC transmitting comments on the

Draft Supplement 24 to the GEIS, related to the license renewal

| application for Nine Mile Point, Units 1 and 2 (Accession No.

| ML053640304)

| December 8, 2005 Email from Mr. Tom Gurdziel, to NRC transmitting comments on the Draft

| Supplement 24 to the GEIS, related to the license renewal application for

| Nine Mile Point, Units 1 and 2 (Accession No. ML060310472)

| December 13, 2005 Letter from Mr. Andrew Raddant U.S. Department of the Interior, to NRC

| transmitting comments on the Draft Supplement 24 to the GEIS, related

| to the license renewal application for Nine Mile Point, Units 1 and 2

| (Accession No. ML060310474)

| December 19, 2005 Letter from Ms. Linda Bond-Clark to NRC transmitting comments on the

| Draft Supplement 24 to the GEIS, related to the license renewal

| application for Nine Mile Point, Units 1 and 2 (Accession No.

| ML060310475)
Appendix C

May 2006 C-7 NUREG-1437, Supplement 24

December 21, 2005 Summary of public meetings conducted to discuss the draft supplemental |

environmental impact statement related to the review of the Nine Mile |

Point Nuclear Station, Units 1 and 2, license renewal application |

(Accession No. ML053550507) |

December 23, 2005 Letter from John Filippelli, EPA, to NRC transmitting comments on the |

Draft Supplement 24 to the GEIS, related to the license renewal |

application for Nine Mile Point, Units 1 and 2 (Accession No. |

ML060110223) |

January 20, 2006 E-mail sent by Kent Stoffle of Constellation to NRC contractor David

Miller regarding information related to the hydrology in the Nine Mile Point

area (Accession No. ML060620591)

January 27, 2006 E-mail sent by Kent Stoffle of Constellation to Leslie Fields of NRC

forwarding documents related to the expiration dates of permits issued by

the state to Nine Mile Point Nuclear Station (Accession No.

ML060970089)

April 18, 2006 E-mail sent by Carla Logan of Constellation to Leslie Fields of NRC

providing information related to fish species at Nine Mile Point Nuclear

Station (Accession No. ML061090052)

Appendix D

Organizations Contacted

May 2006 D-1 NUREG-1437, Supplement 24

Appendix D: Organizations Contacted

During the course of the staff's independent review of environmental impacts from operations

during the renewal term, the following Federal, State, regional, local, and Native American tribal

agencies were contacted:

Advisory Council on Historic Preservation, Washington, D.C.

Cayuga Nation of New York, Versailles, New York

City of Oswego, Oswego, New York

Greater Oswego County Chamber of Commerce, Oswego, New York

New York State Department of Environmental Conservation, Division of Environmental Permits,

Albany, New York

New York State Department of State, Division of Coastal Management, Albany, New York

New York State Department of State, Division of Coastal Resources, Albany, New York

New York State Education Department, Albany New York

New York State Office of Parks, Recreation, and Historic Preservation |

Northeast Regional Office, National Marine Fisheries Service, Gloucester, Maryland

Oneida Indian Nation of New York, Verona, New York

Onondaga Nation, Nedrow, New York

Oswego City School District, Oswego, New York

Oswego County Administrator's Office, Oswego, New York

Oswego County Department of Promotion and Tourism, Oswego, New York

Oswego County Department of Public Works, Oswego, New York

Oswego County Development and Planning Committee, Oswego, New York

Oswego County Health Department, Oswego, New York

Oswego County Planning and Community Development Department, Oswego, New York
Appendix D

NUREG-1437, Supplement 24 D-2 May 2006

Seneca Nation of Indians, Salamanca, New York

St. Regis Band of Mohawk Indians, Akwesasne, New York

State Historic Preservation Office, New York State Office of Parks, Recreation and Historic

Preservation, Albany, New York

Syracuse-Onondaga Planning Agency, Syracuse, New York

Tonawanda Band of Senecas, Basom, New York

Town of Scriba, Oswego, New York

Tuscarora Nation, Lewiston, New York

U.S. Fish and Wildlife Service, Cortland, New York
Appendix E

Nine Mile Point Nuclear Station, LLC, Compliance Status and

Consultation Correspondence

May 2006 E-1 NUREG-1437, Supplement 24

Appendix E: Nine Mile Point Nuclear Station, LLC,

Compliance Status and Consultation Correspondence

Correspondence received during the process of evaluation of the application for renewal of the

license for Nine Mile Point Nuclear Station is identified in Table E-1. Copies of the

correspondence are included at the end of this appendix.

The licenses, permits, consultations, and other approvals obtained from Federal, State,

regional, and local authorities for Nine Mile Point Units 1 and 2, are listed in Table E-2.

Table E-1. Consultation Correspondence

Source Recipient Date of Letter

U.S. Nuclear Regulatory Commission Advisory Council on Historic

Preservation (D. Klima)

July 29, 2004

U.S. Nuclear Regulatory Commission New York State Office of Parks,

Recreation and Historic Preservation

(B. Castro)

August 11, 2004

U.S. Nuclear Regulatory Commission U.S. Fish and Wildlife Service

(M. Moriarty)

August 24, 2004

U.S. Nuclear Regulatory Commission Oswego County Health Department

(N. Roy)

September 16, 2004

U.S. Fish and Wildlife Service

(D. Stilwell)

U.S. Nuclear Regulatory Commission November 3, 2004

U.S. Nuclear Regulatory Commission U.S. Fish and Wildlife Service

(M. Stoll)

November 7, 2004
Table E-2. Federal, State, Local, and Regional Licenses, Permits, Consultations, and Other Approvals for 

Nine Mile Point Units 1 and 2

Agency Authority Description Number Issue Date

ExpirationDate Remarks

NRC 10 CFR Part 50 Operating

license, NineMile Point Unit 1

DPR-63 08/22/09 Authorizes operation

of Unit 1.

NRC 10 CFR Part 50 Operating

license, NineMile Point Unit 2

NPF-69 10/31/26 Authorizes operation

of Unit 2.

FWS Migratory Bird Treaty Act

(16 USC 703-712)

Permit Authorizes carcass

salvage and injuredbird transport.

DOT 49 CFR Part 107, 

Subpart G

Certificate ofRegistration forTransportation ofHazardousMaterials

062104700026M0 06/30/07 Authorization to

transport hazardousmaterials.

New York StateDepartment ofState

Section 307 of theCoastal ZoneManagement Act [16 USC 1456(c)(3)(A)]

Consistencydeterminationwith the NewYork Departmentof State CoastalManagementProgram

New York StateDepartment of Statedetermined thatrenewal of the NineMile Point Units 1 and2 operating licenseswould be consistentwith the New YorkState CoastalManagementProgram.

NYSDEC 6 NYCRR Part 175 New York State

fish and wildlifelicense

523 07/31/06 License for the

collection andpossession of fishand wildlife

NUREG-1437, Supplement 24 E-2 May 2006
Agency Authority Description Number Issue Date

ExpirationDate Remarks

NYSDEC 6 NYCRR Part 325 Pesticide

applicationbusinessregistration

79634 08/02/05 07/31/08 Authorization to apply

pesticide. |

NYSDEC 6 NYCRR Part 373-3 Hazardous

waste interimstatusauthorization

NYD00073042 N/A Allows for

accumulation andtemporary on-sitestorage of mixedwaste greater than 90days.

NYSDEC 6 NYCRR Part 596 Hazardous

waste substancebulk storageregistrationcertificate

7-000058 09/29/05 11/07/07 Authorization for onsite bulk storage of

hazardoussubstances. |

NYSDEC 6 NYCRR Part 613 Petroleum bulk

storageregistrationcertificate

7-429880 11/07/06 Authorization for onsite bulk storage of

petroleum products.

NYSDEC 6 NYCRR Part 675 Water withdrawal

registration

NYGLWWR-3811 11/07/05 11/07/07 Authorization to

withdraw water fromLake Ontario |

NYSDEC 6 NYCRR Part 750 State pollutant

dischargeeliminationsystem permit

NY 000 1015 12/01/09 12/01/09 Permit for discharge

of wastewaters andonce-through coolingwater to the closedcycle recirculatingcooling canal system. Section 1.E.15 of thepermit states that thepermit constitutescertification ofcompliance with §401of the Clean WaterAct.

May 2006 E-3 NUREG-1437, Supplement 24
Agency Authority Description Number Issue Date

ExpirationDate Remarks

State ofTennesseeDepartment ofEnvironmentandConservation

Tennessee CodeAnnotated 68-202-206

RadioactiveShipmentLicense

T-NY002-L06 01/01/06 12/31/06 Authorization to ship

radioactive material toa licenseddisposal/processingfacility withinTennessee.

South CarolinaDepartment ofHealth andEnvironmentalControl

SC ADC 61-83 South Carolina

radioactivewaste transportpermit, Unit 1

0004-31-06-X 11/16/05 12/31/06 Registration to

transport radioactivematerials in SouthCarolina.

South CarolinaDepartment ofHealth andEnvironmentalControl

SC ADC 61-83 South Carolina

radioactivewaste transportpermit, Unit 2

0408-31-06-X 11/16/05 12/31/06 Registration to

transport radioactivematerials in SouthCarolina.

VirginiaDepartment ofEmergencyManagement

9 VAC 20-110-121 Registration for

transport ofradioactivematerial

CE-043006 04/15/04 04/30/06 Authorization to

transport radioactivematerials in Virginia .

CFR = Code of Federal RegulationsDOT = U.S. Department of TransportationFWS = U.S. Fish and Wildlife ServiceNRC = Nuclear Regulatory CommissionNYCRR = New York Code of Rules and RegulationsNYSDEC = New York State Department of Environmental ConservationUSC = United States Code

NUREG-1437, Supplement 24 E-4 May 2006
Appendix E

May 2006 E-5 NUREG-1437, Supplement 24
NUREG-1437, Supplement 24 E-6 May 2006
Appendix E

May 2006 E-7 NUREG-1437, Supplement 24
NUREG-1437, Supplement 24 E-8 May 2006
Appendix E

May 2006 E-9 NUREG-1437, Supplement 24
NUREG-1437, Supplement 24 E-10 May 2006
Appendix E

May 2006 E-11 NUREG-1437, Supplement 24
NUREG-1437, Supplement 24 E-12 May 2006
Appendix E

May 2006 E-13 NUREG-1437, Supplement 24
NUREG-1437, Supplement 24 E-14 May 2006
Appendix E

May 2006 E-15 NUREG-1437, Supplement 24
NUREG-1437, Supplement 24 E-16 May 2006
Appendix E

May 2006 E-17 NUREG-1437, Supplement 24
NUREG-1437, Supplement 24 E-18 May 2006
Appendix E

May 2006 E-19 NUREG-1437, Supplement 24
Appendix F

GEIS Environmental Issues Not Applicable to Nine Mile Point

Units 1 and 2

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the GEIS include the GEIS and its Addendum 1.

May 2006 F-1 NUREG-1437, Supplement 24

Appendix F: GEIS Environmental Issues Not

Applicable to Nine Mile Point Units 1 and 2

Table F-1 lists those environmental issues listed in the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2

(NRC 1996, 1999)(a) and 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are not

applicable to Nine Mile Point Nuclear Station (Nine Mile Point) Units 1 and 2, because of plant

or site characteristics.

Table F-1. GEIS Environmental Issues Not Applicable to Nine Mile Point Units

1 and 2

ISSUE—10 CFR Part 51, Subpart A,

Appendix B, Table B-1 Category

GEIS

Sections Comment

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered salinity gradients 1 4.2.1.2.2;

4.4.2.2

Nine Mile Point Units 1 and 2 cooling

systems do not discharge to an

estuary.

Water-use conflicts (plants with cooling

ponds or cooling towers using makeup

water from a small river with low flow)

2 4.3.2.1;

4.4.2.1

Nine Mile Point Units 1 and 2 cooling

systems do not use makeup water

from a small river with low flow.

GROUNDWATER USE AND QUALITY

Groundwater use conflicts (potable and

service water, and dewatering; plants

that use <100 gpm)

1 4.8.1.1;

4.8.1.2

Nine Mile Point Units 1 and 2 do not

use less than 100 gpm groundwater.

Groundwater-use conflicts (plants

using cooling towers withdrawing

makeup water from a small river)

2 4.8.1.3;

4.4.2.1

This issue is related to heatdissipation systems that are not

installed at Nine Mile Point Units 1

and 2.

Groundwater-use conflicts 

(Ranney wells)

2 4.8.1.4 Nine Mile Point Units 1 and 2 do not

have or use Ranney wells.

Groundwater quality degradation

(Ranney wells)

1 4.8.2.2 Nine Mile Point Units 1 and 2 do not

have or use Ranney wells.

Groundwater quality degradation

(cooling ponds in salt marshes)

2 4.8.3 Nine Mile Point Units 1 and 2 do not

have or use cooling ponds.
Appendix F

ISSUE—10 CFR Part 51, Subpart A,

Appendix B, Table B-1 Category

GEIS

Sections Comment

NUREG-1437, Supplement 24 F-2 May 2006

Groundwater quality degradation

(cooling ponds at inland sites)

1 4.4.4 Nine Mile Point Units 1 and 2 do not

have or use cooling ponds.

TERRESTRIAL RESOURCES

Cooling pond impacts on terrestrial

resources

1 4.4.4 This issue is related to a heatdissipation system that is not

installed at Nine Mile Point.

HUMAN HEALTH

| Microbial organisms (public health)

(plants using lakes or canals, or cooling

towers or cooling ponds that discharge

to a small river

2 4.3.6 Nine Mile Point Units 1 and 2 cooling

systems do not discharge to a small

river.

References

| 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants: Main Report, Section 6.3, Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report. 

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.
Appendix G

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Nine Mile Point Units 1 and 2

May 2006 G-1 NUREG-1437, Supplement 24

Appendix G: NRC Staff Evaluation of Severe Accident Mitigation

Alternatives (SAMAs) for Nine Mile Point Units 1 and 2

G.1 Introduction

Nine Mile Point Nuclear Station, LLC (NMPNS) submitted an assessment of SAMAs for Nine

Mile Point Units 1 and 2 as part of the Environmental Report (ER) (NMPNS 2004a). 

Unit-specific analyses were performed for both of the units since the designs, as well as the risk

profiles, for the two units are much different (Unit 1 is a boiling water reactor (BWR)/2 with a

Mark I containment; Unit 2 is a BWR/5 with a Mark II containment.) The SAMA assessments

were based on the most recent Nine Mile Point Probabilistic Risk Assessment (PRA) for each

unit available at that time, a plant-specific offsite consequence analysis performed using the

MELCOR Accident Consequence Code System 2 (MACCS2), and insights from the Nine Mile

Point Individual Plant Examination (IPE) (NMPC 1992, 1993) and Individual Plant Examination

of External Events (IPEEE) for each unit (NMPC 1995, 1996). In identifying and evaluating

candidate SAMAs, NMPNS considered SAMA analyses performed for other operating plants

that have submitted license renewal applications, as well as industry and NRC documents that

| discuss potential plant improvements. NMPNS identified 220 potential SAMA candidates. This

list was reduced to 13 (Unit 1) and 20 (Unit 2) unique SAMA candidates by eliminating SAMAs

that were not applicable to Nine Mile Point due to design differences, had already been

implemented, or had high implementation costs. NMPNS assessed the costs and benefits

associated with each of the remaining SAMAs and concluded in the ER that four of the

candidate SAMAs evaluated for Unit 1 and 11 of the SAMAs evaluated for Unit 2 would be

potentially cost-beneficial.

Based on a review of the SAMA assessment, the NRC issued a request for additional

information (RAI) to NMPNS by letter dated October 20, 2004 (NRC 2004a) and email dated

December 29, 2004 (NRC 2004b). Key questions concerned: peer reviews of the PRA and the

potential impact of unresolved comments; release characteristics and classification criteria;

dominant risk contributors at Nine Mile Point and the SAMAs that address these contributors;

the potential impact of uncertainties on the assessment results; the status of potential

improvements identified in the IPE and IPEEE; detailed information on some specific candidate

SAMAs; and, consideration of additional SAMAs. NMPNS submitted additional information by

letters dated December 6, 2004 (NMPNS 2004b) and January 31, 2005 (NMPNS 2005). In the

responses, NMPNS provided: summaries of peer review comments; tables containing

| information on release categories and characteristics; listings of important basic events along

with corresponding SAMA candidates addressing those events; an assessment of the impact of

uncertainties; information related to the potential plant improvements identified in the IPE and

IPEEE; and additional information regarding specific SAMAs. NMPNS's responses addressed

the staff's concerns, and did not result in the identification of any additional potentially

cost-beneficial SAMAs.

An assessment of SAMAs for Nine Mile Point is presented below.
Appendix G

NUREG-1437, Supplement 24 G-2 May 2006

G.2 Estimate of Risk for Nine Mile Point

NMPNS's estimates of offsite risk at Nine Mile Point are summarized in Section G.2.1. The

summary is followed by the staff's review of NMPNS's risk estimates in Section G.2.2.

G.2.1 NMPNS's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the Nine Mile Point Level 1 and 2 PRA model, which includes both internal and

external events models based on updated versions of the IPE (NMPC 1992, 1993) and IPEEE

(NMPC 1995, 1996), and (2) a supplemental analysis of offsite consequences and economic

impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The

SAMA analysis is based on the most recent Level 1 and 2 PRA model available at the time of

the ER, referred to as the PRA01B model for each unit.

The baseline core damage frequency (CDF) values for the purpose of the SAMA evaluation are

approximately 2.7 x 10-5 per year for Unit 1, and 6.2 x 10-5 per year for Unit 2. The CDF values

are based on the risk assessment for both internally and externally initiated events. 

The breakdown of CDF by functional contribution is provided in Table G-1. This information is

compiled from that provided in the ER and in the responses to RAIs (NMPNS 2004a and

2004b). A more detailed breakdown of the major contributors is provided in the RAI response

(NMPNS 2004b). According to the response, loss of injection due to fires and station blackout

(SBO) are dominant contributors to the CDF for Unit 1. At Unit 2, SBO, loss of injection due to

internal events, and loss of heat removal are dominant contributors to CDF. For Unit 1, fires

contribute 49 percent and seismic events contribute five percent to the total CDF. Internal

flooding events were screened from further consideration. For Unit 2, fires contribute six

percent, internal floods contribute two percent and seismic events contribute one percent to the

total CDF. 

The Level 2 PRA models are based on the original Level 2 models from the IPE; however, the

source terms were updated based on more recent analyses. The conditional probabilities,

fission product release fractions, and release characteristics for each release category were

provided in response to RAIs (NMPNS 2004b, 2005).
Appendix G

May 2006 G-3 NUREG-1437, Supplement 24

Table G-1. Nine Mile Point Core Damage Frequency

Unit 1 Unit 2

Initiator or Accident Class

CDF 

(Per Year)

Percent

Contribution

to CDF

CDF 

(Per Year)

Percent

Contribution

to CDF

Loss of support systems 7.8 x 10-6 29 4.7 x 10-5 75

Transients 4.1 x 10-6 15 8.1 x 10-6 13

Loss of coolant accidents (LOCAs) 5.4 x 10-7 2 1.2 x 10-6 2

Internal floods NR(a) NR(a) 1.2 x 10-6 2

Internal Events CDF 1.3 x 10-5 46 5.8 x 10-5 93

Fires 1.3 x 10-5 49 3.7 x 10-6 6

Seismic activity 1.3 x 10-6 5 6.2 x 10-7 1

External Events CDF 1.4 x 10-5 54 4.3 x 10-6 7

Total CDF 2.7 x 10-5 100 6.2 x 10-5 100

(a) NR not reported; was screened from analysis

The offsite consequences and economic impact analyses use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for these analyses

include plant-specific and site-specific input values for core radionuclide inventory, source term

and release characteristics, site meteorological data, projected population distribution (within a

80 km [50-mi] radius) for the year 2030, emergency response evacuation modeling, and

economic data. The core radionuclide inventory is based on the generic BWR inventory

provided in the MACCS2 manual, adjusted to represent the Nine Mile Point power levels of

1850 MW(t) for Unit 1 and 3467 MW(t) for Unit 2. The magnitude of the onsite impacts (in terms

of clean-up and decontamination costs and occupational dose) is based on information provided

in NUREG/BR-0184 (NRC 1997c).

In the ER, NMPNS estimated the dose to the population within 80 km (50 mi) of the Nine Mile

Point site to be approximately 0.225 person-Sv (22.5 person-rem) per year for Unit 1, and

0.509 person-Sv (50.9 person-rem) per year for Unit 2. The breakdown of the total population

dose by containment release mode is summarized in Table G-2. Containment failures within

the intermediate timeframe (6 to 24 hours following event initiation) and late timeframe (greater

than 24 hours following event initiation) dominate the population dose risk at Nine Mile Point.
Appendix G

NUREG-1437, Supplement 24 G-4 May 2006

Table G-2. Breakdown of Population Dose by Containment Release Mode

Unit 1 Unit 2

Containment Release Mode

Population

Dose

(PersonRem(a) Per

Year)

Percent

Contribution

Population

Dose

(PersonRem(a) Per

Year)

Percent

Contribution

Early containment failure 5.0 22 5.9 12

Intermediate containment failure 10.0 44 12.2 24

Late containment failure 7.5 34 32.71 64

No containment failure (leakage) 0.01 <1 0.1 <1

Total Population Dose 22.5 100 50.9 100

(a) 1 person-Rem = 0.01 person-Sv

G.2.2 Review of NMPNS's Risk Estimates

NMPNS's determination of offsite risk at Nine Mile Point is based on the following three major

elements of analysis:

• the Level 1 and 2 risk models that form the bases for the Unit 1 and Unit 2 IPE submittals

(NMPC 1992, 1993) and the IPEEE submittals (NMPC 1995, 1996),

• the major modifications to the IPE model that have been incorporated in the Nine Mile Point

PRAs, and

• the MACCS2 analyses performed to translate fission product source terms and release

frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of NMPNS's risk estimates

for the SAMA analysis, as summarized below. 

The staff's review of the Nine Mile Point IPEs is described in NRC reports dated April 2, 1996

for Unit 1 (NRC 1996), and August 18, 1994 for Unit 2 (NRC 1994). Based on a review of the

original IPE submittals and responses to RAIs, the staff concluded that the IPE submittals met

the intent of Generic Letter 88-20; that is, the IPEs were of adequate quality to be used to look

for design or operational vulnerabilities. 
Appendix G

May 2006 G-5 NUREG-1437, Supplement 24

A comparison of internal events CDF from the IPE and the PRA used in the SAMA analysis

indicates an increase of approximately 7.5 x 10-6 per year in the CDF for Unit 1 (from 5.5 x 10-6 |

per year to 1.3 x 10-5 per year). For Unit 2, the increase in CDF was about 2.7 x 10-5 per year

(from 3.1 x 10-5 per year to 5.8 x 10-5 per year). The increase is mainly attributed to modeling

changes that have been implemented since the IPEs were submitted. A summary listing of

those changes that resulted in the greatest impact on the internal events CDF was provided in

the ER, and include:

Unit 1

• added several initiating events for support system failures,

• updated and improved reactor pressure vessel overfill modeling to be consistent with unit

modifications to reduce the probability of the event,

• improved modeling of loss of instrumentation scenarios, and

• improved modeling of containment heat removal recovery.

Unit 2

• revised and improved the SBO model based on updated human reliability evaluations and

plant-specific events,

• improved modeling of the safety relief valves to allow recovery of dominant failure modes,

• improved modeling of containment heat removal recovery, 

• added more detailed modeling of electrical switchgear to improve the modeling of

dependencies, and

• added more detailed modeling of service water and improved the success criteria.

The Nine Mile Point Unit 1 IPE CDF value is at the low end of the range of the CDF values

reported in the IPEs for boiling BWR 1/2/3 plants, while the IPE CDF value for Unit 2 is in the

middle of the range of the CDF values reported in the IPEs for BWR 5/6 plants. Figure 11.2 of

NUREG-1560 shows that the IPE-based CDF for BWR 1/2/3 plants ranges from 3 x 10-6 to 

5 x 10-5 per year, and for BWR 5/6 plants, the CDF ranges from 1 x 10-5 to 6 x 10-5 per year

(NRC 1997a). It is recognized that other plants have generally reduced the values for CDF

subsequent to the IPE submittals due to modeling and hardware changes. The current internal

events CDF results for Nine Mile Point remain comparable to other plants of similar vintage and

characteristics.
Appendix G

NUREG-1437, Supplement 24 G-6 May 2006

The staff considered the peer reviews performed for the Nine Mile Point PRAs, and the potential

impact of the review findings on the SAMA evaluation. In response to an RAI, NMPNS

described the previous peer reviews, the most significant of which was the Boiling Water

Reactor Owners Group (BWROG) Peer Reviews (NMPNS 2004b). These reviews were

conducted in 1998 (Unit 1) and 1997 (Unit 2), and were reviews of slightly modified versions of

the IPEs. In response to an RAI, NMPNS stated that all Level A facts and observations were

incorporated in the PRA models used for the SAMA analyses, and that none of the Level B facts

and observations that have not yet been incorporated would significantly impact the CDF or the

SAMA results (NMPNS 2005). These Level B facts and observations were provided in the RAI

response. The staff agrees that none of the facts and observations would adversely affect the

PRAs to a degree that would invalidate their use for the SAMA evaluations.

Given that the Nine Mile Point PRAs have been peer reviewed and the peer review findings

were either addressed or judged to have no impact on the SAMA evaluation, that NMPNS

satisfactorily addressed staff questions regarding the PRA (NMPNS 2004b, 2005), and that the

CDF falls within the range of contemporary CDFs for BWR plants with Mark I and Mark II

containments, the staff concludes that the Level 1 PRA model is of sufficient quality to support

the SAMA evaluation.

Niagara Mohawk Power Company (NMPC) submitted IPEEEs in August 1996 (Unit 1) and June

1995 (Unit 2), in response to Supplement 4 of Generic Letter 88-20 (NMPC 1996, 1995). 

NMPC did not identify any fundamental weaknesses or vulnerabilities to severe accident risk in

regard to the external events related to seismic, fire, or other external events. However, a

number of areas were identified for improvement in both the seismic and fire areas and were

subsequently addressed as discussed below. In letters dated July 18, 2000 and August 12,

1998, the staff concluded that the submittals met the intent of Supplement 4 to Generic Letter

88-20, and that the licensee's IPEEE process was capable of identifying the most likely severe

accidents and severe accident vulnerabilities (NRC 2000, 1998).

Unit 1 Seismic Analysis

The Unit 1 IPEEE uses a focused scope EPRI seismic margins analysis (SMA). This method is

semi-quantitative and does not directly provide the means to determine the numerical estimates

of the CDF contributions from seismic initiators. All equipment in the seismic IPEEE scope was

reviewed in accordance with Unresolved Safety Issue (USI) A-46 program procedures. Based

on the EPRI assessment methodology, NMPC found that, after IPEEE identified improvements

were made, all components in the assessment success path had high confidence low

probability of failure (HCLPF) values less than the 0.3g review level earthquake except for two

items:

• battery boards 11 and 12 0.27g

• containment spray raw water pumps 0.29g
Appendix G

May 2006 G-7 NUREG-1437, Supplement 24

The HCLPF values for these two items are considered to be sufficiently close to the screening

value as to essentially meet the review level earthquake requirements. In response to a

SAMA-related RAI regarding the IPEEE, NMPNS stated that the improvements needed to meet

the 0.3g HCLPF screening criteria (excluding the two items above) were tracked and completed

under the USI A-46 program (NMPNS 2004b).

NMPNS addressed the potential for cost-beneficial SAMAs to address the above two items that

have HCLPF values less than the screening values (NMPNS 2005). NMPNS stated that based

on previous SAMA evaluations, a reduction in CDF of 1 x 10-7 per year would yield a benefit of

about $10K, and a reduction of 1 x 10-6 per year would yield a benefit of about $100K. To

accurately establish a change in CDF would require a more detailed seismic fragility and risk

evaluation, which would easily exceed $100K in cost. With regard to the battery boards,

NMPNS stated that the difference in risk between the 0.27g HCLPF and 0.3 g HCLPF screening

value is closer to 1 x 10-6 per year because DC power is important to the automatic operation of

equipment, particularly since the seismic event is likely to have also caused a loss of offsite

power. The modifications needed to achieve a 0.3 g HCLPF value were estimated to cost in

excess of $100K. In addition to the expense of the seismic evaluation ($100K), this modification

would not be cost-beneficial. With regard to the containment spray raw water pumps, NMPNS

stated that the difference in risk is not distinguishable between the 0.29 g HCLPF and the 0.3 g

HCLPF screening value. Therefore, the change in risk is likely to be closer to 1 x 10-7 per year

(i.e., $10K benefit) since the failure of these pumps primarily impacts the containment heat

removal function. In order to achieve the 0.3 g HCLPF, it is likely that the four pumps would be

required to be replaced (because the pump casing length would exceed the 20-ft limit allowed

under USI A-46). This cost alone would exceed any achievable benefit. NMPNS concluded

that the cost of increasing the seismic capacity of these items would exceed any potential

benefit. The staff agrees with this conclusion.

The IPEEE extended the seismic margins methodology to include determination of a seismic

CDF. The seismic CDF after making the identified improvements was estimated in the IPEEE

to be 1 x 10-6 | per year. The NRC's Safety Evaluation Report (SER) on the IPEEE concluded

that this CDF, based solely on the seismic margins assessment, potentially underestimates the

true seismic CDF (NRC 2000). Subsequent to the IPEEE, the Nine Mile Point Unit 1 PRA was

updated to incorporate external events. The seismically induced CDF is given as five percent of

the total CDF (or approximately 1.3 x 10-6 per year). A description of the updated seismic risk

assessment was provided in response to a SAMA-related RAI and appears very similar to that

utilized in the IPEEE (NMPNS 2004b). The staff notes that even if the seismic CDF is several

times greater than the PRA assessed value it would still be a relatively small contributor to

overall risk for Nine Mile Point Unit 1. The staff’s conclusion is that the analysis, while

somewhat simplified and utilizing a number of significant assumptions, incorporates the

important factors that affect seismic risk and provides an estimate of seismic CDF and risk

suitable for the present application. 
Appendix G

NUREG-1437, Supplement 24 G-8 May 2006

Unit 2 Seismic Analysis

The Unit 2 IPEEE initially used a focused scope EPRI seismic margins analysis using a 0.5 g

review level earthquake rather than the required 0.3 g. NMPC found that for a 24-hour mission

time all of the plant's high confidence low probability of failure (HCLPF) values were more than

the 0.5 g review level earthquake except for HFA Model 154 relay chatter, which had a HCLPF

value of 0.45 g. For the long term (a 72-hour mission time) it was determined that makeup was

dependent on non-seismic nitrogen bottles, which had a HCLPF value of 0.23 g. Additionally,

three concerns were cited in the IPEEE: (1) potential for an overhead rack to impact a

motor-operated valve (MOV); (2) potential interaction of hoist assemblies mounted on electric

cabinets; and (3) fire water piping in the control building with less than 0.5 g HCLPF. NMPC

stated in the IPEEE that the first two concerns had been resolved. A detailed evaluation

subsequent to the walkdown concluded that a HCLPF of 0.5 g could be justified for the fire

piping.

NMPC also performed a Level 2 seismic PRA to put the SMA results into perspective. The

seismic CDF after making the identified improvements is given as 2.5 x 10-7 per year. It is noted

that even though the two evaluations appear very similar, the NRC's SER on the IPEEE for Nine

Mile Point Unit 2 did not express the same concerns about the seismic risk results as were

expressed for the Nine Mile Point Unit 1 evaluation. Subsequent to the IPEEE, the NMP2 PRA

was updated to incorporate external events. The seismically-induced CDF is given as one

percent of the total CDF (or approximately 6 x 10-7 per year). A description of the updated

seismic risk assessment was provided in response to an RAI and is very similar to that utilized

in the IPEEE (NMPNS 2004b). The staff notes that even if the seismic CDF is several times

greater than the PRA assessed value it would still be a relatively small contributor to overall

Nine Mile Point risk for Unit 2. The assessment specifically included the contribution due to

failure of the nitrogen bottles that had a HCLPF of 0.23 g. The staff notes that the failure

frequency of these bottles combined with the failure of other systems necessary to lead to core

damage result in a CDF contribution so low that a SAMA addressing this issue is unlikely to be

cost-beneficial. The staff concludes that while somewhat simplified and utilizing a number of

significant assumptions, the analysis incorporates the important factors that affect seismic risk

and provides an estimate of seismic CDF and risk suitable for the present application. 

Based on the licensee's efforts to identify and address seismic outliers, the staff concludes that

the opportunity for seismic-related SAMAs has been adequately explored for Nine Mile Point

Units 1 and 2 and that there are no cost-beneficial, seismic-related SAMA candidates.

The IPEEE fire analysis for both Nine Mile Point Unit 1 and Unit 2 consisted of a fire PRA that

utilized portions of the Fire Induced Vulnerability Evaluation (FIVE) methodology. A single

quantitative screening was initially performed, followed by a detailed analysis of the unscreened

fire areas. The screening consisted of making an initial CDF estimate from a fire frequency

estimate based on the amount of fixed and transient combustibles in each area and a

conditional core damage frequency determined from the IPE. A CDF screening criterion of 
Appendix G

May 2006 G-9 NUREG-1437, Supplement 24

1 x 10-6 per year was applied to each zone or area. The detailed analysis considered the

location of ignition sources, combustibles and critical components in each area, along with fire

detection and suppression capabilities to determine the fire CDF in each unscreened area. 

Unit 1 Fire Analysis

The IPEEE Nine Mile Point Unit 1 fire CDF, after making IPEEE-identified improvements, is

given as 2 x 10-5 per year. The principal contributors are given below.

Fire Zone Location

Core Damage Frequency

(per year)

T3B Turbine Bldg. El 261' South 1.3 x 10-5

C1 Cable Spreading Room 2.0 x 10-6

C3 Auxiliary Control Room 1.4 x 10-6

C2 Main Control Room 1.1 x 10-6

T2B Turbine Bldg. El 250' South & West 1.0 x 10-6

Subsequent to the IPEEE, the Nine Mile Point Unit 1 PRA was updated to incorporate external

events. As part of the update, the external events modeling from the IPEEE was improved,

resulting in a reduction in external event risk. The updated fire-induced CDF is given as 

1.3 x 10-5 per year, or approximately 49 percent of the total CDF. In response to an RAI,

NMPNS provided a listing of the contribution to loss of injection events by initiating event, and a

listing of basic event importance for CDF (NMPNS 2004b). These lists include numerous

indications of the importance of fire events in the current PRA and are reasonably consistent

with the above IPEEE results. Also, SAMA U1-210 addresses fires related to the dominant fire

source from the IPEEE, and indicates a CDF reduction reasonably consistent with the above

results. Based on this and the results of the NRC IPEEE review, the staff concludes that the

current fire PRA results provide an adequate basis for considering these events in the SAMA

evaluations.

Unit 2 Fire Analysis

The IPEEE Nine Mile Point Unit 2 fire CDF is given as 1.4 x 10-6 per year, which is

approximately one decade lower than the fire CDF for Nine Mile Point Unit 1. The principal

contributors to this are fires in various main control room cabinets. Subsequent to the IPEEE,

the Nine Mile Point Unit 2 PRA was updated to incorporate external events. As part of the

| update, the external events modeling from the IPEEE was improved, resulting in an increase in

external event risk. The updated fire-induced CDF is given as 3.7 x 10-6 per year, or

approximately six percent of the total CDF. In response to an RAI, NMPNS provided a listing of
Appendix G

NUREG-1437, Supplement 24 G-10 May 2006

the contribution to loss of injection events by initiating event, and a listing of basic event

importance for CDF (NMPNS 2004b). These lists include numerous indications of the

| importance of fire events in the current PRA and are reasonably consistent with the IPEEE

results. Based on this and the results of the NRC IPEEE review, the staff concludes that the

current fire PRA results provide an adequate basis for considering these events in the SAMA

evaluations.

The Nine Mile Point Unit 1 IPEEE SER estimated that high wind loads contribute a CDF of 

1.6 x 10-6 per year, tornado missiles contribute 3.5 x 10-7 per year and probable maximum

participation contributes 6 x 10-7 per year. The Nine Mile Point Unit 1 IPEEE demonstrated that

transportation and nearby facility accidents were not considered to be significant vulnerabilities

at the plant without quantitative estimates. The staff concluded in the SER that these results did

not indicate vulnerabilities to these other external hazards. 

Using a progressive screening approach, the Nine Mile Point Unit 2 IPEEE concluded that

contributions to CDF from other external events (high winds, tornado, transportation and nearby

facility accidents, etc.) are insignificant (less than 1 x 10-6 per year). The SER on the NMP2

IPEEE concurred in this assessment.

Because NMPNS included contributions to risk from seismic and fire in its base case evaluation,

and due to the efforts made during the IPEEE process to address seismic issues, the staff finds

NMPNS's consideration of external events to be acceptable for purposes of the SAMA

evaluation.

NMPNS stated that the Level 2 models used to determine the frequency of the various release

categories include no major changes from the IPE models (NMPNS 2004a). The Level 2

analysis processes each core damage sequence individually through the Level 2 model. 

NMPNS characterized the releases for the spectrum of possible radionuclide release scenarios

using a set of ten release categories, defined based on the timing and magnitude of the release. 

Each end state of the Level 2 analysis corresponds to one of the release categories. The

release categories and their frequencies are presented in Tables F.2-5 and F.2-6 of the ER for

Units 1 and 2, respectively (NMPNS 2004a). In response to an RAI, NMPNS provided the

source terms for each release category and the basis for these values (NMPNS 2004b, 2005). 

The source terms were based on a combination of new plant specific MAAP 4.0 analysis and

comparisons with source term results from NUREG/CR-4551 for Peach Bottom (NRC 1990a). 

All releases were modeled as occurring at 30 m above ground level. This is based on the

expectation that regardless of containment failure location, the building panels will be blown out

| and most releases will pass through the building and exit near the refueling level. The staff

concludes that the process used for determining the release category frequencies and source

terms is reasonable and appropriate for the purposes of the SAMA analysis.
Appendix G

May 2006 G-11 NUREG-1437, Supplement 24

As discussed previously, the fission product inventories used in the consequence analyses are

based on a fission product inventory scaled from generic information for each unit. In response

to an RAI concerning the impact of current and future fuel management practices, NMPNS

described a conservative analysis of core fission product inventory based on a bounding case of

1400 effective full power days (EFPD) versus the expected average core exposure at

end-of-cycle of approximately 1277 EFPD (NMPNS 2005). The staff estimates that using this

increased inventory would result in about a 20 percent increase in the total costs associated

with a severe accident. Using realistic mid-life or average conditions would result in a smaller

increase. Based on this limited impact, the staff concludes that the scaling based on the

plant-specific power level yields sufficiently accurate and reasonable results for the dose

assessment.

The staff reviewed the process used by NMPNS to extend the containment performance

(Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3

PRA). This included consideration of the major input assumptions used in the offsite

consequence analyses. The MACCS2 code was utilized to estimate offsite consequences. 

Plant-specific input to the code includes the source terms for each release category and the

reactor core radionuclide inventory (both discussed above), site-specific meteorological data,

projected population distribution within a 80-km (50-mi) radius for the year 2030, emergency

evacuation modeling, and economic data. This information is provided in Appendix F of the ER

(NMPNS 2004a).

NMPNS used site-specific meteorological data processed from hourly measurements for the

1994 calendar year as input to the MACCS2 code. Data from 1985 through 2001 were also

considered, but data from 1994 was selected because it was considered to be "average" for

items of interest, with no extremes in the annual averages or joint frequency distributions. Data

voids were filled using various techniques, including substitution of alternate data from a backup

tower or from alternate measurement levels, and interpolation between data points. The staff

notes that previous SAMA analyses results have shown little sensitivity to year-to-year

differences in meteorological data and considers use of the 1994 data in the base case to be

reasonable.

The population distribution the applicant used as input to the MACCS2 analysis was estimated

for the year 2030, based on SECPOP90 (NRC 1997b). The 1990 rosette populations generated

by SECPOP90 were extrapolated to the year 2030 by using the ratio of 1990/2030 county

populations multiplied by the estimated fraction of each county comprising the rosette section. 

The county-specific population projections were obtained from Cornell University. A sensitivity

analysis was performed in which the projected population in all sectors was increased by ten

percent. The increase in projected population results in approximately a seven percent

increase (applicable to both units) in population dose risk, but less than a five percent increase

in total costs associated with a severe accident. The staff considers the methods and

assumptions for estimating population reasonable and acceptable for purposes of the SAMA

evaluation.
Appendix G

NUREG-1437, Supplement 24 G-12 May 2006

The emergency evacuation model was modeled as a single evacuation zone extending out

16 km (10 mi) from the plant. It was assumed that 95 percent of the population would move at

an average speed of approximately 1.8 meters per second with a delayed start time of

7200 seconds (NMPNS 2004a). This assumption is conservative relative to the NUREG-1150

study (NRC 1990b), which assumed evacuation of 99.5 percent of the population within the

emergency planning zone. A sensitivity study performed on the evacuation speed

demonstrated that the total dose and economic cost results are insensitive to this parameter. 

The evacuation assumptions and analysis are deemed reasonable and acceptable for the

purposes of the SAMA evaluation.

Much of the site-specific economic data were provided from SECPOP90 (NRC 1997c) by

specifying the data for each of the ten counties surrounding the plant, to a distance of 80 km (50

mi). The SECPOP90 input file was manually updated to 2000 using cost of living and other data

from the Bureau of the Census and the Department of Agriculture. The agricultural economic

data were updated using available data from the 1997 Census of Agriculture (USDA 1998)

supplemented by data available through other Federal agencies.

The staff concludes that the methodology used by NMPNS to estimate the offsite consequences

for Nine Mile Point provides an acceptable basis from which to proceed with an assessment of

risk reduction potential for candidate SAMAs. Accordingly, the staff based its assessment of

offsite risk on the CDF and offsite doses reported by NMPNS.

G.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by NMPNS are discussed in this section.

G.3.1 Process for Identifying Potential Plant Improvements

NMPNS's process for identifying potential plant improvements (SAMAs) consisted of the

following elements: 

• review of plant-specific improvements identified in the Nine Mile Point IPE and IPEEE and

subsequent PRA revisions

• review of SAMA analyses submitted in support of original licensing and license renewal

activities for other operating nuclear power plants

• review of other NRC and industry documentation discussing potential plant improvements.

Based on this process, an initial set of 220 candidate SAMAs was identified, representing a

compilation of 204 SAMAs identified from previous plant analyses, and 16 SAMAs identified
Appendix G

May 2006 G-13 NUREG-1437, Supplement 24

from the NMP-specific PRAs. In Phase 1 of the evaluation, NMPNS performed a qualitative

screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the

following criteria: 

• the SAMA is not applicable to the plant design,

• the SAMA has already been implemented,

• the SAMA is similar to another SAMA under consideration, or 

• the SAMA is not feasible, has associated costs that exceed the maximum attainable benefit,

or does not provide a significant benefit.

Based on this screening, 207 SAMAs were eliminated for Unit 1 and 200 SAMAs were

eliminated for Unit 2, leaving 13 and 20 for further evaluation for Units 1 and 2, respectively. Of

the SAMAs eliminated at Unit 1, 45 were eliminated because they were not applicable, 25 were

similar to other SAMAs being considered, 65 had been implemented, 63 either had no

significant safety benefit or had implementation costs greater than any risk benefit, and nine

were related to the mitigation of ISLOCA, which is considered to be a low risk contributor, and

the SAMA was not developed further. Of the SAMAs eliminated at Unit 2, 37 were eliminated

because they were not applicable, 30 were similar to other SAMAs being considered, 66 had

been implemented, 53 either had no significant safety benefit or had implementation costs

greater than any risk benefit, nine were related to the mitigation of ISLOCA (as explained

above), and seven were related to reactor coolant pump seal leakage (only considered for

Unit 2). The remaining SAMAs are listed in Tables 4.16-3 (Unit 1) and 4.16-4 (Unit 2) of the ER

(NMPNS 2004a), and were subjected to further evaluation. 

For the final evaluation, NMPNS estimated the cost of implementing the SAMA, as described in

Section G.5 below, and the associated potential risk reduction and dollar-equivalent benefit, as

described in Sections G.4 and G.6 below. Of the 13 SAMAs surviving the initial screening for

Unit 1, four were identified as potentially cost-beneficial. Of the 20 SAMAs surviving the initial

screening for Unit 2, 11 SAMAs were identified as potentially cost-beneficial.

G.3.2 Review of NMPNS's Process

NMPNS's efforts to identify potential SAMAs focused on unit-specific risk and design

characteristics. The initial list of SAMAs generally addressed the accident sequences

considered to be important to CDF from functional, initiating event, and risk reduction worth

perspectives. NMPNS also considered SAMAs to address improvements in containment

performance but concluded that such modifications are expensive, and, therefore, screened

them out with the exception of one SAMA related to containment venting (SAMA 212).
Appendix G

NUREG-1437, Supplement 24 G-14 May 2006

The preliminary review of NMPNS's SAMA identification process raised some concerns

regarding the completeness of the set of SAMAs identified and the inclusion of plant-specific

risk contributors. The staff requested clarification regarding the portion of risk represented by

the dominant risk contributors (NRC 2004a). In response to the RAI, NMPNS provided a listing

of basic events ranked using the Fussell-Vesely (FV) importance measure for both CDF and

large early release frequency (LERF) (NMPNS 2004b). NMPNS considered basic events with a

FV greater than 0.01. NMPNS correlated the top risk contributors to CDF and LERF with the

SAMAs evaluated in the ER (NMPNS 2004b). Based on these assessments, NMPNS

concluded that the set of 220 SAMAs evaluated addressed the major contributors to CDF and

large release frequency, and that the review of the top risk contributors did not reveal any new

SAMAs.

The staff noted that for several important basic events, the associated SAMAs identified as

addressing the basic event were not included within the set of 13 and 20 SAMAs that survived

the initial screening for Unit 1 and Unit 2, respectively, and were not described elsewhere in the

ER. In response to a staff request, NMPNS provided supplemental information describing each

of these SAMAs (eight additional SAMAs for Unit 1 and five additional SAMAs for Unit 2), and

the cost and benefit considerations on which NMPNS screened these SAMAs from further

consideration in Phase 1 (NMPNS 2005). The staff reviewed the description of the potential

enhancement and the screening criterion assigned (e.g., not applicable, already installed, etc.)

and agrees that these SAMAs do warrant further consideration for the reasons provided in the

response.

NMPNS considered potential improvements to further reduce external events risk. The Nine

Mile Point PRA models include external initiating events (fires, seismic, and floods). The risk

profile for Unit 1 indicates that fires contribute almost half of the CDF. As a result, SAMA

U1-210, protect critical fire targets, was identified and retained for evaluation. Although seismic

events are important contributors to LERF, NMPNS concluded that no further evaluation was

necessary since any modification to improve the fragility of the plant would be costly. At Unit 2,

flooding in the control building was identified as an important contributor to LERF. Therefore,

SAMA U2-223, improve control building flood scenarios, was identified and retained for

evaluation.

While neither IPE identified vulnerabilities, both did identify a number of potential improvements,

some of which were implemented and credited in the IPEs and others which were identified for

future consideration. The staff questioned the applicant about the current status of these

potential improvements (NRC 2004a). In response to the RAI, NMPNS provided the current

status of the IPE identified improvements/enhancements. All have either been implemented,

previously evaluated and determined not needed to be considered further, or are addressed by

SAMAs in the present analysis (NMPNS 2004b).

The staff also questioned NMPNS about the consideration of SAMAs previously identified by

other BWR plants as potentially cost-beneficial (NRC 2004a). In response to the RAI, NMPNS
Appendix G

May 2006 G-15 NUREG-1437, Supplement 24

provided an assessment of the applicability/feasibility of each of the specific enhancements

identified by the staff, and concluded that these SAMAs either would not provide a significant

benefit or were not feasible/applicable at Nine Mile Point (NMPNS 2004b).

The staff notes that the set of SAMAs submitted is not all-inclusive, since additional, possibly

even less expensive, design alternatives can always be postulated. However, the staff

concludes that the benefits of any additional modifications are unlikely to exceed the benefits of

the modifications evaluated and that the alternative improvements would not likely cost less

than the least expensive alternatives evaluated, when the subsidiary costs associated with

maintenance, procedures, and training are considered. 

The staff concludes that NMPNS used a systematic and comprehensive process for identifying

potential plant improvements for Nine Mile Point, and that the set of potential plant

improvements identified by NMPNS is reasonably comprehensive and therefore acceptable. 

This search included reviewing insights from the IPE and IPEEE and other plant-specific

studies, reviewing plant improvements considered in previous SAMA analyses, and using the

knowledge and experience of its PRA personnel.

G.4 Risk Reduction Potential of Plant Improvements

NMPNS evaluated the risk-reduction potential of the 13 (Unit 1) and 20 (Unit 2) remaining

SAMAs that were applicable to Nine Mile Point. Many of the SAMA evaluations were performed

in a bounding fashion in that the SAMA was assumed to completely eliminate the risk

associated with the proposed enhancement. Such bounding calculations overestimate the

benefit and are conservative.

NMPNS used model re-quantification to determine the potential benefits. The CDF and

population dose reductions were estimated using the PRA01B version of the Nine Mile Point

PRAs. The changes made to the model to quantify the impact of SAMAs are detailed in Section

F.3 of Appendix F to the ER (NMPNS 2004a), and in the response to the RAI (NMPNS 2004b). 

Tables G-3 and G-4 list the assumptions considered to estimate the risk reduction for each of

the evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF and

population dose, and the estimated total benefit (present values) of the averted risk based on a

seven-percent and three-percent discount rate. The determination of the benefits for the

various SAMAs is further discussed in Section G.6.

Several of the SAMAs were judged by NMPNS to have a negligible benefit based on a

determination that both CDF and population dose would not be significantly impacted by their

implementation (e.g., SAMAs U1-24, U1-112, and U2-21). In these instances, the SAMA affects

sequences that are not risk-significant at Nine Mile Point, or the SAMA is ineffective, i.e., the

SAMA does not provide a significant benefit because the failure would still occur due to another

means.
Appendix G

NUREG-1437, Supplement 24 G-16 May 2006

The staff has reviewed NMPNS's bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what

would actually be realized). Accordingly, the staff based its estimates of averted risk for the

various SAMAs on NMPNS's risk reduction estimates.

G.5 Cost Impacts of Candidate Plant Improvements

NMPNS estimated the costs of implementing the 13 (Unit 1) and 20 (Unit 2) candidate SAMAs. 

The cost estimates conservatively did not include the cost of replacement power during

extended outages required to implement the modifications, nor did they include contingency

costs associated with unforeseen implementation obstacles. Estimates were presented in

terms of dollar values at the time of implementation or estimation, and were not adjusted to

present-day dollars. For some of the SAMAs considered, the cost estimates were sufficiently

greater than the benefits calculated that it was not necessary to perform a detailed cost

estimate.

The staff reviewed the bases for the applicant's cost estimates (presented in Section F.3 of

Appendix F to the ER). For certain improvements, the staff also compared the cost estimates to

estimates developed elsewhere for similar improvements, including estimates developed as part

of other licensees' analyses of SAMAs for operating reactors and advanced light-water reactors. 

The staff reviewed the costs and found them to be consistent with estimates provided in support

of other plants' analyses.

NMPNS did not provide a cost estimate for SAMA U2-218, which seeks to improve the highpressure core spray cross-tie to Division I/II. NMPNS stated that upon further evaluation of the

proposed modification, it was determined that the design concept was not feasible for

implementation to achieve the modeled benefit. SAMAs U2-215 (use of a portable charger),

U2-216 (hard pipe diesel fire pump to the reactor pressure vessel) and U2-221 (reduce unit

cooler contribution to emergency diesel generator unavailability), all of which were identified as

| potentially cost-beneficial for Unit 2, were judged by NMPNS to provide a more reliable and

cost-effective alternative to SAMA U2-218. Implementation of any or all of these potentially

cost-beneficial SAMAs would reduce the estimated benefit of SAMA U2-218. Considering the

above rationale, and that the benefit estimated by NMPNS for U2-218 has been conservatively

determined, the staff agrees that further consideration of SAMA U2-218 is not warranted.

The staff concludes that the cost estimates provided by NMPNS are sufficient and appropriate

for use in the SAMA evaluation.
Table G-3. SAMA Cost/Benefit Screening Analysis for Nine Mile Point Unit 1

% Risk

Reduction

SAMA Assumptions CDF

PopulationDose

Total Benefit ($)7% Discount Rate

Total Benefit ($)

3% Discount Rate Cost ($)

U1-4 Procedure revision andtraining on loss of reactor buildingclosed loop cooling

Operator action failure probability isimproved from 0.1 to 1E-3

<1 <1 8600 12,000 30,000

U1-21 Firewater supply to shutdown |

cooling heat exchanger

Failure of shutdown coolingmodified to include success byusing fire pump with no operatorerror

2.3 2 41,400 58,000 500,000

U1-24 Improved procedures for lossof control room HVAC

Screened out based on furtherconsideration of existing procedures

~0 ~0 ~0 ~0 NA

U1-112 Modify reactor watercleanup (RWCU) for decay heatremoval

RWCU provides adequate heatremoval in all shutdown events inwhich its support systems areavailable

~0 ~0 ~0 ~0 >1 million

U1-113 Use of control rod drive(CRD) for alternate boron injectionFailure of standby liquid controlreduced by 2 orders of magnitude

Failure of standby liquid controlreduced by 2 orders of magnitude

<1 <1 5500 7700 >70,000

U1-208 Improve drywell head bolts Bounding analysis by eliminating

drywell failure modes in Level 2analysis

0 <0.1 1500 2000 >150,000

U1-209 Improve standardoperating procedure SOP-14 andprovide training

Human error probabilities inmodel for loss of vital AC powerreduced by factor of 10

22 24 449,000 627,500 30,000

U1-210 Protect critical fire targets Risk from dominant fire sources

set to zero

23 24 459,000 641,500 40,000

May 2006 G-17 NUREG-1437, Supplement 24

Appendix G
% Risk

Reduction

SAMA Assumptions CDF

PopulationDose

Total Benefit ($)7% Discount Rate

Total Benefit ($)

3% Discount Rate Cost ($)

U1-211 Reduce offsite dependencyon battery board DC11 

Offsite Power Recovery within andafter 1 hour revised to allow use ofanother battery board with operatorerror of 0.1

<1 2 24,400 34,000 50,000

U1-212 Capability to manuallyoperate containment venting 

Containment venting modelrevised to allow local manualoperation of valve 201-16

<1 2 37,500 52,400 >40,000

U1-215 Add a portable batterycharger

Human error probabilities inmodel for loss of vital AC powerreduced by factor of 10

22 24 449,000 627,500 50,000

U1-220 Installation of newtransformers to improve AC powerload management 

Operator error to shed loadseliminated from model thusassuming perfect operator ortransformers replaced

14 17 295,000 411,000 600,000

U1-222 Improved response to lossof instrument air

U1-Model revised to reflect perfectlyreliable operator on loss ofinstrument air or feedwater controlsystem independent of instrumentair

4 5 87,500 122,000 600,000

Note: SAMAs in bold were judged to be potentially cost-beneficial.

NUREG-1437, Supplement 24 G-18 May 2006

Appendix G
Table G-4. SAMA Cost/Benefit Screening Analysis for Nine Mile Point Unit 2

% Risk

Reduction

SAMA Assumptions CDF

PopulationDose

Total Benefit ($)7% Discount Rate

Total Benefit ($)

3% Discount Rate Cost ($)

U2-21 Firewater supply toshutdown cooling heat exchanger 

Failure of shutdown coolingmodified to include success byusing fire pump with no operatorerror

~0 ~0 ~0 ~0 >100,000

U2-23a Provide redundantventilation for residual heatremoval pump rooms

Room cooling is perfectly reliable 3 7 210,000 293,500 30,000

U2-23b Provide redundantventilation for high pressurecore spray (HPCS) pump room

Room cooling is perfectly reliable 4 8 264,000 369,000 30,000

U2-23c Provide redundantventilation for reactor coreisolation cooling pump room

Room cooling is perfectly reliable 1 2 77,500 108,300 30,000

U2-24 Improve procedures forloss of control room HVAC

Screened out based on furtherconsideration of existing proceduresand low contribution to CDF fromventilation failure

~0 ~0 ~0 ~0 NA

U2-56 Additional diesel for onsiteemergency AC power

New diesel generator with failureprobability of 0.01 included. Nocredit if non-recoverable emergencybus failures or fire in emergencyswitchgear area occur

54 5 956,000 1,220,000 >10 million

U2-73 Firewater back up foremergency diesel generatorcooling

Fire water required to fail in additionto service water in order to failemergency diesel generators.Human error assumed to be zero

3 5 135,000 184,000 500,000

May 2006 G-19 NUREG-1437, Supplement 24

Appendix G
% Risk

Reduction

SAMA Assumptions CDF

PopulationDose

Total Benefit ($)7% Discount Rate

Total Benefit ($)

3% Discount Rate Cost ($)

U2-112 Modify RWCU for decayheat removal

RWCU provides adequate heatremoval in all shutdown events inwhich its support systems areavailable

~0 ~0 ~0 ~0 >1 million

U2-113 Use CRD for alternateboron injection

Failure of standby liquid controlreduced by 2 orders of magnitude

<1 1 46,800 63,900 >150,000

U2-208 Improve drywell headbolts

Bounding analysis by eliminatingdrywell failure modes in Level 2analysis

0 2 30,700 43,000 >150,000

U2-213 Enhance loss of servicewater procedure

Room cooling is perfectly reliable 4 8 264,000 369,000 30,000

U2-214 Enhance SBOprocedures

A detailed assessment was notperformed

Note 2 Note 2 >100,000 >139,000 30,000

U2-215 Use of portable batterycharger

U2-Failure probability of portablebattery charger reduced from 0.96to 0.05

5 20 507,000 708,000 50,000

U2-216 Hard pipe diesel firepump to the reactor pressurevessel 

Failure probability for fire pumpto provide sufficient flow reducedfrom 0.8 to 1E-05 with samehuman error for operator toconnect

42 8 800,000 1,112,000 200,000

U2-218 Improve the HPCScrosstie to division I/II

Human error probabilities for failureof operator to implement crosstiereduced to 1E-03

41 4 706,000 986,000 NA

U2-219 Improve containmentventing

Human error probability for operatorto vent containment reduced by afactor of 10

4 11 313,000 437,000 700,000

NUREG-1437, Supplement 24 G-20 May 2006

Appendix G
% Risk

Reduction

SAMA Assumptions CDF

PopulationDose

Total Benefit ($)7% Discount Rate

Total Benefit ($)

3% Discount Rate Cost ($)

U2-221a Reduce unit coolercontribution to emergencydiesel generator (EDG)unavailability— increasetesting frequency

Reduced standby failureprobability from that for 5 yearexposure time to that for a onecycle exposure time

14 6 342,000 478,000 55,000

U2-221b Reduce unit coolercontribution to EDGunavailability— provideredundant means of cooling

Once per cycle test interval andreduction in unavailability byfactor of 10 to account foralternate means of room cooling

31 18 872,000 1,218,000 55,000

U2-222 Improve procedures forloss of instrument air

Model revised to eliminatefeedwater failure on loss ofinstrument air but add operatorerror with the same value as thatfor feedwater recovery for smallLOCA

7 7 273,000 382,000 30,000

U2-223 Improve controlbuilding flooding scenarios

Frequency of flood in controlbuilding reduced by order ofmagnitude

1 3 86,700 121,000 >100,000

Note 1: SAMAs in bold were judged to be potentially cost-beneficial.Note 2: Compensatory measures are currently used during the applicable alignments during certain electrical configurations. These compensatory measures will

be permanently added to appropriate procedures. Therefore, a detailed assessment was not performed.

May 2006 G-21 NUREG-1437, Supplement 24

Appendix G
Appendix G

NUREG-1437, Supplement 24 G-22 May 2006

G.6 Cost-Benefit Comparison

NMPNS's cost-benefit analysis and the staff's review are described in the following sections.

G.6.1 NMPNS Evaluation

The methodology used by NMPNS was based primarily on NRC's guidance for performing

cost-benefit analysis, i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation

Handbook (NRC 1997c). The guidance involves determining the net value for each SAMA

according to the following formula:

Net Value = (APE + AOC + AOE + AOSC) - COE

where,

APE = present value of averted public exposure ($)

AOC = present value of averted offsite property damage costs ($)

AOE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($)

COE = cost of enhancement ($).

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. NMPNS's derivation

of each of the associated costs is summarized below.

NUREG/BR-0058 has recently been revised to reflect the agency's revised policy on discount

rates. Revision 4 of NUREG/BR-0058 states that two sets of base case estimates should be

developed—one at three percent and one at seven percent (NRC 2004c). NMPNS provided

both sets of estimates and stated that it would consider for further evaluation any SAMA that

was cost-beneficial using a three percent discount rate.

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure ( person-rem/year)

x monetary equivalent of unit dose ($2000 per person-rem)

x present value conversion factor (10.76 based on a 20-year period with a

seven percent discount rate).

As stated in NUREG/BR-0184 (NRC 1997c), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public
Appendix G

May 2006 G-23 NUREG-1437, Supplement 24

health risk due to a single accident. Rather, it is the present value of a stream of potential

losses extending over the remaining lifetime (in this case, the renewal period) of the facility. 

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. For the purposes of initial screening, NMPNS

calculated an APE of approximately $484,000 (Unit 1) and $1,100,000 (Unit 2) for the 20-year

license renewal period, which assumes elimination of all severe accidents.

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction 

x offsite economic costs associated with a severe accident (on a

per-event basis)

x present value conversion factor.

For the purposes of initial screening, which assumes all severe accidents are eliminated,

NMPNS calculated an annual offsite economic risk of about $86,100 (Unit 1) and $125,000 (Unit

2) based on the Level 3 risk analysis. This results in a discounted value of approximately

$927,000 (Unit 1) and $1,350,000 (Unit 2) for the 20-year license renewal period.

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor.

NMPNS derived the values for averted occupational exposure from information provided in

Section 5.7.3 of the regulatory analysis handbook (NRC 1997c). Best estimate values provided

for immediate occupational dose (3300 person-rem) and long-term occupational dose

(20,000 person-rem over a 10-year cleanup period) were used. The present value of these

doses was calculated using the equations provided in the handbook in conjunction with a

monetary equivalent of unit dose of $2000 per person-rem, a real discount rate of seven

percent, and a time period of 20 years to represent the license renewal period. For the

purposes of initial screening, which assumes all severe accidents are eliminated, NMPNS

calculated an AOE of approximately $10,200 (Unit 1) and $23,500 (Unit 2) for the 20-year

license renewal period.
Appendix G

NUREG-1437, Supplement 24 G-24 May 2006

Averted Onsite Costs (AOSC)

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted

power replacement costs. Repair and refurbishment costs are considered for recoverable

accidents only and not for severe accidents. NMPNS derived the values for AOSC based on

information provided in Section 5.7.6 of the regulatory analysis handbook (NRC 1997c).

NMPNS divided this cost element into two parts—the Onsite Cleanup and Decontamination

Cost, also commonly referred to as averted cleanup and decontamination costs, and the

replacement power cost.

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC = Annual CDF reduction

x present value of cleanup costs per core damage event

x present value conversion factor.

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

the regulatory analysis handbook to be $1.5 x 109

 (undiscounted). This value was converted to

present costs over a 10-year cleanup period and integrated over the term of the proposed

license extension.

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = Annual CDF reduction

x present value of replacement power for a single event

x factor to account for remaining service years for which replacement power

is required

x reactor power scaling factor

NMPNS based its calculations on the value of 615 MWe (Unit 1) and 1144 MWe (Unit 2). 

Therefore, NMPNS applied power scaling factors of 615 MWe/910 MWe for Unit 1 and

1144 MWe/910 MWe for Unit 2 to determine the replacement power costs. For the purposes of

initial screening, which assumes all severe accidents are eliminated, NMPNS calculated the

AOSC to be approximately $456,000 for Unit 1 and $1,330,000 for Unit 2.

Using the above equations, NMPNS estimated the total present dollar value equivalent

associated with completely eliminating severe accidents at Nine Mile Point Unit 1 to be about

$1,900,000, and at Nine Mile Point Unit 2 to be about $3,800,000. 
Appendix G

May 2006 G-25 NUREG-1437, Supplement 24

NMPNS's Results

If the implementation costs were greater than $2,000,000 (Unit 1), or $5,000,000 (Unit 2), then

the SAMA was screened from further consideration. A more refined look at the costs and

benefits was performed for the remaining SAMAs. If the expected cost for those SAMAs

exceeded the calculated benefit, the SAMA was considered not to be cost-beneficial. The

cost-benefit results for the individual analysis of the 13 SAMA candidates (Unit 1) and the

20 SAMA candidates (Unit 2) are presented in Tables G-3 and G-4, respectively. In the

baseline analysis, using a seven percent discount rate, three SAMAs were considered to be

potentially cost-beneficial for Unit 1, and ten were considered to be potentially cost-beneficial for

Unit 2. NMPNS performed sensitivity analyses to evaluate the impact of parameter choices on

the analysis results (NMPNS 2004a). Based on the sensitivity analysis using a three percent

discount rate, two additional SAMA candidates were determined to be potentially

cost-beneficial, i.e., SAMA U1-212 and SAMA U2-223. The potentially cost-beneficial

SAMAs are:

Unit 1

• SAMA U1-209—Improve Procedure SOP-14 and provide training: This SAMA involves a

procedure revision to prevent the loss of power assuming operators are able to maintain

control of the plant.

• SAMA U1-210—Protect critical fire targets: This SAMA would protect critical fire targets

from dominant fire sources by moving some of the targets or sources to improve separation

and/or providing cable tray protection (e.g., barrier board).

• SAMA U1-212—Add capability to manually operate containment venting: This SAMA

involves adding the capability to manually operate the valve that vents primary containment

by adding a hand wheel or local air tank (cost-beneficial at three percent discount rate).

• SAMA U1-215—Add a portable charger: This SAMA involves the use of a portable charger

for charging the batteries to extend the coping time when AC power has been lost.

Unit 2

• SAMA U2-23a—Provide redundant ventilation for residual heat removal (RHR) pump rooms: 

This SAMA involves a revision of the operating procedure to provide additional space

cooling via the use of portable equipment or blocking doors open.

• SAMA U2-23b—Provide redundant ventilation for high pressure core spray (HPCS) pump

room: This SAMA is similar to SAMA U2-23a.
Appendix G

NUREG-1437, Supplement 24 G-26 May 2006

• SAMA U2-23c—Provide redundant ventilation for reactor core isolation cooling (RCIC) pump

room: This SAMA is similar to SAMA U2-23a.

• SAMA U2-213—Enhance loss of service water procedure: This SAMA involves a procedure

enhancement of the Unit 2 loss of service water procedure (SOP-11) to provide more

specific guidance for events involving loss of service water.

• SAMA U2-214—Enhance SBO procedures: This SAMA involves a procedure enhancement

of the SBO procedure to provide entry conditions into SOP-3 and SOP-1 for some of the

important failure modes during certain electrical configurations.

• SAMA U2-215—Use of a portable charger for the batteries: This SAMA would provide an

additional capability for maintaining the 125V DC battery charged given loss of emergency

AC power combined with the capability to align the ADS and containment venting related

solenoid-operated valves to DC power (via the uninterruptable power supply).

• SAMA U2-216—Hard pipe diesel fire pump to the reactor pressure vessel: This SAMA

involves a hardware modification to allow the diesel fire pump to provide injection to the

reactor pressure vessel (RPV).

• SAMA U2-221a—Reduce unit cooler contribution to emergency diesel generator (EDG)

unavailability increase testing frequency: This SAMA would provide a more reliable means

of cooling the EDG control panel rooms by testing the unit coolers during every cycle.

• SAMA U2-221b—Reduce unit cooler contribution to EDG unavailability provide redundant

means of cooling: This SAMA would also provide a more reliable means of cooling the EDG

control panel rooms by providing guidance for operators to open the EDG control panel

room doors.

• SAMA U2-222—Improve procedure for loss of instrument air: This SAMA involves an

enhancement to loss of instrument air procedure N2-SOP-19 to provide a better means of

responding to loss of instrument air.

• SAMA U2-223—Improve control building flooding scenarios: This SAMA may involve

structural modifications such as a water-tight door or piping modifications (to move firewater

header) in order to eliminate the flood source (cost-beneficial at three percent discount rate).

It is noted that several of the SAMAs are not independent; that is, implementation of one SAMA

could achieve a portion of the benefit of the others. For example, implementing SAMA U1-215

would significantly reduce the benefit of SAMA U1-209. Similarly, implementation of SAMAs

U2-23a, -23b, -23c, and -213 can be considered as a combination since loss of service water

(SAMA U2-213) is an important contributor and cause of room cooling failure (SAMA U2-23). 

NMPNS indicated that relationships between the SAMAs have not yet been modeled.
Appendix G

May 2006 G-27 NUREG-1437, Supplement 24

| G.6.2 Review of NMPNS's Cost-Benefit Evaluation

The cost-benefit analysis performed by NMPNS was based primarily on NUREG/BR-0184 (NRC

1997c) and was executed consistent with this guidance. 

In response to an RAI, NMPNS considered the uncertainties associated with the internal events

CDF by evaluating those candidate SAMAs that are within a factor of three of being

cost-beneficial (based on a seven percent discount rate) (NMPNS 2004b). For Unit 1, three

such SAMAs were identified:

• U1-211—Reduce offsite dependency on battery board DC11

• U1-212—Capability to manually operate containment venting

• U1-220—Installation of new transformers to improve AC power load management

NMPNS noted that SAMA U1-215 (add a portable battery charger) provides a more reliable

alternative for addressing the vulnerability associated with reducing the dependency on offsite

power than SAMA U1-211, and its implementation will reduce the benefit of U1-211. (SAMA

U1-215 is among the potentially cost-beneficial SAMAs identified by NMPNS for further

evaluation). Therefore, further evaluation of U1-211 is not warranted. The staff agrees with this

assessment.

As noted above, SAMA U1-212 is already among the set of potentially cost-beneficial SAMAs

identified by NMPNS, having been identified as potentially cost-beneficial using a three percent

discount rate. As such, this SAMA will be further evaluated.

NMPNS also stated that SAMA U1-220 is not warranted at this time due to the conservatism

that exists in the model and in the cost estimation. In a follow-up question, the staff asked

NMPNS to elaborate on and justify the conservatism in the model (NRC 2005). In response,

NMPNS stated that in the model, the probability of operator error is set to zero, and that

although it may be reasonable to remove the operator action in question due to the addition of

new transformers, the baseline risk would be overstated for this operator action because a

single human failure basic event is used in the model for both redundant power boards. This

assumes complete dependency between human failures that could lead to overloading both

redundant power boards. In reality, operator load management activities as well as timing could

be different for each emergency power division, thereby reducing the dependency assumption. 

NMPNS also indicated that further review of the modification revealed that the transformers are

attached to their corresponding power boards, thereby complicating the modification and

increasing the engineering and installation costs. Therefore, NMPNS concluded that this SAMA

would not be within a factor of three of being potentially cost-beneficial (NMPNS 2005). The

staff agrees with this assessment.
Appendix G

NUREG-1437, Supplement 24 G-28 May 2006

For NMP Unit 2, the following SAMAs were identified as being within a factor of three of being

cost-beneficial (based on a seven percent discount rate) (NMPNS 2004b):

• U2-219—Improve containment venting

• U2-223—Improve control building flooding scenarios

NMPNS stated that for U2-219, it conservatively modeled the benefit of full automation by not

considering competing risks, and also underestimated the implementation costs. Additional

costs in the amount of $250,000 would be needed to install multiple valves and operators, hard

piping, and valve actuation circuitry and logic. Therefore, this SAMA would no longer be within

a factor of three of being cost-beneficial. The staff agrees with this assessment.

As noted above, SAMA U2-223 is already among the set of potentially cost-beneficial SAMAs

identified by NMPNS, having been identified as potentially cost-beneficial using a three percent

discount rate. As such, this SAMA will be further evaluated.

NMPNS performed sensitivity analyses that addressed assumptions made in other parts of the

cost-benefit analysis, including population, fission product release, and evacuation

assumptions. The evacuation sensitivity demonstrated that results are insensitive to this

parameter. The other sensitivity cases (e.g., population and fission product release) resulted in

less than a ten percent change in both offsite dose and offsite economic risks. 

The staff concludes that, with the exception of the four potentially cost-beneficial SAMAs for

Unit 1 and the 11 potentially cost-beneficial SAMAs for Unit 2, the costs of the SAMAs would be

higher than the associated benefits.

G.7 Conclusions

NMPNS compiled a list of 220 SAMA candidates using the SAMA analyses submitted in support

of licensing activities for other nuclear power plants, NRC and industry documents discussing

potential plant improvements, plant-specific insights from the NMP IPE and IPEEE, and the

current PRA models for Unit 1 and 2. An initial screening removed SAMA candidates that: 

(1) are not applicable at Nine Mile Point due to design differences, (2) have already been

implemented at Nine Mile Point, (3) are sufficiently similar to another SAMA under

consideration, or (4) are not feasible, have associated costs that exceed $2M (Unit 1) or $5M

(Unit 2), or do not provide a significant benefit. A total of 207 SAMAs were eliminated for Unit 1

and 200 SAMAs were eliminated for Unit 2, leaving 13 and 20 for further evaluation,

respectively.

For the remaining SAMA candidates, a more detailed design and cost estimate was developed

as shown in Tables G-3 and G-4. The cost-benefit analyses using a seven percent discount
Appendix G

May 2006 G-29 NUREG-1437, Supplement 24

rate showed that three of the 13 SAMA candidates are potentially cost-beneficial for Unit 1 and

ten of the 20 SAMA candidates are potentially cost-beneficial for Unit 2. Upon completion of a

three percent discount rate sensitivity study, an additional SAMA candidate was determined to

be potentially cost-beneficial at each unit. NMPNS considered those SAMAs that were within a

factor of three of being cost-beneficial, and concluded that no additional SAMAs would become

cost-beneficial.

The staff reviewed the NMPNS analysis and concluded that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

supports the general conclusion that the SAMA evaluations performed by NMPNS are

reasonable and sufficient for the license renewal submittal. The inclusion of external events

afforded the quantitative evaluation of SAMAs specifically aimed at reducing risk from external

events.

The staff agrees with NMPNS's identification of areas in which risk can be further reduced in a

cost-beneficial manner through the implementation of all or a subset of the identified, potentially

cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the staff agrees

that further evaluation of these SAMAs by NMPNS is warranted. However, none of the

potentially cost-beneficial SAMAs relate to adequately managing the effects of aging during the

period of extended operation. Therefore, they need not be implemented as part of the license

renewal pursuant to 10 CFR Part 54.

G.8 References

Electric Power Research Institute (EPRI). 1991. A Methodology for Assessment of Nuclear

Power Plant Seismic Margins, Revision 1, EPRI Report NP-6041-SL.

Electric Power Research Institute (EPRI). 1995. Fire PRA Implementation Guide. Science

Applications International Corporation, EPRI Report TR-104031, December 1995.

Niagara Mohawk Power Corporation (NMPC). 1992. Letter from J. F. Firlit, NMPC, to U.S.

Nuclear Regulatory Commission Document Control Desk. Subject: Nine Mile Point Unit 2,

Docket No. 50-410, NPF-69, Individual Plant Examination (IPE) Final Report, July 30, 1992.

Niagara Mohawk Power Corporation (NMPC). 1993. Letter from C. D. Terry, NMPC, to U.S.

Nuclear Regulatory Commission Document Control Desk. Subject: Nine Mile Point Unit 1,

Docket No. 50-220, DPR-63, Individual Plant Examination, Generic Letter 88-20, July 27, 1993.

Niagara Mohawk Power Corporation (NMPC). 1995. Letter from C. D. Terry, NMPC, to U.S.

Nuclear Regulatory Commission Document Control Desk. Subject: Nine Mile Point Unit 2,

Docket No. 50-410, NPF-69, Individual Plant Examination of External Events (IPEEEs) Severe
Appendix G

NUREG-1437, Supplement 24 G-30 May 2006

Accident Vulnerabilities—10CFR50.54(f) (Generic Letter No. 88-20, Supplement 4), 

June 30, 1995.

Niagara Mohawk Power Corporation (NMPC). 1996. Letter from C. D. Terry, NMPC, to U.S.

Nuclear Regulatory Commission Document Control Desk. Subject: Nine Mile Point Unit 1,

Docket No. 50-220, DPR-63, Individual Plant Examination of External Events (IPEEEs) Severe

Accident Vulnerabilities—10CFR50.54(f) (Generic Letter No. 88-20, Supplement 4), 

August 29, 1996.

Nine Mile Point Nuclear Station, LLC (NMPNS). 2004a. Applicant's Environmental Report

Operating License Renewal Stage, Nine Mile Point Units 1 and 2. Nine Mile Point Nuclear

Station, LLC, Annapolis, Maryland, May 2004.

Nine Mile Point Nuclear Station, LLC (NMPNS). 2004b. Letter from James A. Spina, NMPNS,

to U.S. NRC Document Control Desk. Subject: Nine Mile Point Units 1 and 2, Docket Nos.

50-220 and 50-410, Facility Operating License Nos. DPR-63 and NPF-69, License Renewal

Application Responses to NRC Requests for Additional Information Regarding the Analysis of

Severe Accident Mitigation Alternatives (TAC Nos. MC3274 and MC3275), December 6, 2004.

Nine Mile Point Nuclear Station, LLC (NMPNS). 2005. Letter from James A. Spina, NMPNS, to

the U.S. NRC Document Control Desk. Subject: Nine Mile Point Units 1 and 2, Docket Nos.

50-220 and 50-410, Facility Operating License Nos. DPR-63 and NPF-69, License Renewal

Application Revised and/or Supplemental Responses to NRC Requests for Additional

Information Regarding the Analysis of Severe Accident Mitigation Alternatives (TAC Nos.

MC3274 and MC3275), January 31, 2005.

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant

Examination for Severe Accident Vulnerabilities," November 23, 1988.

U.S. Nuclear Regulatory Commission (NRC). 1990a. Evaluation of Severe Accident Risks:

Peach Bottom, Unit 2. NUREG/CR-4551, Vol. 4, Rev. 1, Part 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1990b. Severe Accident Risks: An Assessment

for Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991. Procedural and Submittal Guidance for the

Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. 

NUREG-1407, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1994. Letter from Pao-Tsin Kuo, U.S. NRC, to

B. Ralph Sylvia, Niagara Mohawk Power Corporation (NMPC). Subject: Individual Plant

Examination for Nine Mile Point Nuclear Station, Unit 2 (TAC No. M74437), August 18, 1994.
Appendix G

March 2005 G-31 NUREG-1437, Supplement 24

U.S. Nuclear Regulatory Commission (NRC). 1996. Letter from Darl S. Hood, U.S. NRC, to

B. Ralph Sylvia, Niagara Mohawk Power Corporation (NMPC). Subject: NRC Staff's Evaluation 

of the Nine Mile Point Nuclear Station Unit No. 1 Individual Plant Examination (TAC No.

M74436), April 2, 1996.

U.S. Nuclear Regulatory Commission (NRC). 1997a. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. SECPOP90: Sector Population, Land

Fraction, and Economic Estimation Program. NUREG/CR-6525, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997c. Regulatory Analysis Technical Evaluation

Handbook. NUREG/BR-0184, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1998. Letter from Darl S. Hood, U.S. NRC, to

John H. Mueller, Niagara Mohawk Power Corporation (NMPC). Subject: Review of Individual

Plant Examination of External Events, Nine Mile Point Nuclear Station, Unit No. 2 (TAC No.

M83646), August 12, 1998.

U.S. Nuclear Regulatory Commission (NRC). 2000. Letter from Peter S. Tam, U.S. NRC, to

John H. Mueller, Niagara Mohawk Power Corporation (NMPC). Subject: Nine Mile Point Unit 1 

Individual Plant Examination of External Events (TAC No. M83645), July 18, 2000.

U.S. Nuclear Regulatory Commission (NRC). 2002a. Perspectives Gained From the IPEEE

Program, Final Report, Vols. 1 and 2, NUREG-1742, Washington, D.C., April 2002.

U.S. Nuclear Regulatory Commission (NRC). 2004a. Letter from Leslie C. Fields, U.S. NRC, to

James A. Spina, NMPNS. Subject: Request for Additional Information (RAI) Regarding Severe

Accident Mitigation Alternatives for the Nine Mile Point Nuclear Station, Units 1 and 2 (TAC Nos.

MC3274 and MC3275), October 20, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004b. Email from Jennifer Davis, U.S. NRC, to

Dennis Vandeputte, NMPNS. Subject: NMP RAI Response Follow Up Questions,

December 29, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004c. Regulatory Analysis Guidelines of the

U.S. Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C. 

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National

Agriculture Statistics Service, 1998. Available online at: 

http://www.nass.usda.gov/census/census97/volume1/vol1pubs.htm. (Accession No.

ML060960401)
BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1437, Supplement 24

3. DATE REPORT PUBLISHED

MONTH

May

YEAR

2006

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS)

Supplement 24 

Regarding Nine Mile Point Nuclear Station, Units 1 and 2 

Final Report

5. AUTHOR(S)

See Appendix B of report

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of License Renewal

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as 8 above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket Numbers 50-220, 50-410

11. ABSTRACT (200 words or less)

This final supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted to

the NRC by Nine Mile Point Nuclear Station, LLC to renew the operating licenses for Nine Mile Point Nuclear Station, Units 1

and 2 (Nine Mile Point) for an additional 20 years under 10 CFR Part 54. The final SEIS includes the NRC staff's analysis that

considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the

proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staff's

recommendation regarding the proposed action.

The NRC staff's recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for Nine Mile Point are not so great that preserving the option of license renewal for energy-planning decision makers would be

unreasonable. The recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental Report

submitted by Nine Mile Point Nuclear Station, LLC; (3) consultation with Federal, State, and local agencies; (4) the staff's own

independent review; and (5) the staff's consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Nine Mile Point Nuclear Station, Units 1 and 2 

NMP

Nine Mile Point

Final Supplement to the Generic Environmental Impact Statement

FSEIS

National Environmental Policy Act

NEPA

License Renewal

GEIS

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001